AI Governance Briefing — August 15, 2025
Zeph Tech is stress-testing EU AI Act systemic-risk incident reporting so GPAI models meet Article 55's 15-day notification clock and mitigation expectations.
Executive briefing: Article 55 of the EU AI Act requires GPAI providers whose models create systemic risk to notify the European Commission and national authorities of serious incidents without undue delay, and no later than fifteen days after detection. Zeph Tech is validating its incident response pipeline—ensuring severity classification, legal review, and customer communications finish within the Article 55 window while mitigation plans launch in parallel.
Regulatory checkpoints
- 15-day deadline. Article 55(3) sets the outer bound for reporting serious incidents once providers are aware of them, demanding auditable detection timestamps.
- Mitigation evidence. Providers must document remedial steps, risk reductions, and monitoring outcomes alongside the notification.
- Deployer assistance. Article 53(4) obliges providers to support deployers during mitigation, including configuration changes or downgraded models.
Control alignment
- Integrated incident command. Align AI incident management with enterprise crisis procedures so legal, security, and policy leads co-sign regulator filings.
- Log retention. Preserve model telemetry, evaluation artefacts, and customer communications in tamper-evident stores for regulator audits.
Detection and response priorities
- Simulate systemic-risk scenarios—harmful content escalation, safety bypasses, or large-scale privacy failures—to verify the Article 55 response clock.
- Auto-populate incident templates with severity data, affected use cases, and mitigation owners to accelerate regulator submissions.
- Track outstanding mitigations and close-out reports so follow-up communications occur within agreed timelines.
Enablement moves
- Provide EU clients with notification guidance describing how Zeph Tech will communicate incidents and what artefacts they should retain.
- Host tabletop exercises with EU AI Office liaisons and national regulators to rehearse data exchanges and questions.
- Review insurance and indemnity clauses to ensure Article 55 incident liabilities are covered.
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